ML20101H038
| ML20101H038 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/11/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101G904 | List: |
| References | |
| 227, NUDOCS 8412280109 | |
| Download: ML20101H038 (6) | |
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VIRGINIA ELECTRIC AND Powsu ' COMPANY Rtcuxown,VIBGINIA 20261
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May 11, 1984 Mr. James P. O'Reilly Serial No. 227 Regional Administrator N0/JHL:acm Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 101 Marietta Street, Suite 2900 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
We have received your letter of March 30, 1984, in reference to the inspection conducted at North Anna Power Station between February 6, 1984 and March 5, 1984 and reported in IE Inspection Report Nos. 50-338/84-04 and 50-339/84-04.
Per a telephone conversation between Mr. W. R. Cartwright and Mr..S. A. Elrod, on April 27, 1984, an extension until May 11, 1984 was granted to respond to this inspection report. Our response to the specific infraction and deviation is attached.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric'and Power Company has no objection to this inspection report being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours,
/
V W. L. Stewar, f Attachment cc:
Mr. Richard C. Lewis, Director Division of Project and Resident Programs Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station h
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Attachment Pp1 Serial No. 227 r
RESPONSE TO~ NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/84-04 AND 50-339/84-04 i
NRC COMMENT:
Technical Specification 6.8.1 requires written procedures be established, implemented and maintained. North Anna Power Station Administrative Procedure ADM 14.1 (September 14, 1983)
Temporary Modifications, controls the installation, use and removal of jumpers and temporary modifications.
Contrary to the requirements of ADM 14.1:
a.
Unit 2 " jumper.176 did not have a jumper: form in the _ log.
b.
The jumper logs contain over 30 jumpers that are well past their expected removal dates, and they have not been removed or updated.
c.
Unit 1 jumper 224 system drawing does not reflect the present jumper piping status.
d.
The form for Unit 1 jumper 842 is checked as safety-related and has an attached safety evalu.ttion, but does not have the signature of the Superintendent of Operations or his designee.
e.
The safety evaluations for Unit l' jumpers 879 and 880 were not adequate in that the effects of a failure of the temporary repairs were not completely addressed.,
This is a Severity Level IV Violation and applies to both units.
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
This Violation is correct as stated.
(2) REASONS FOR VIOLATION:
The reasons for the specific problems noted are as follows:
i a.
Unit 2 jumper 176 was installed on August 26, 1980. This jumper form was removed from the logbook for review and.not returned in a timely manner. This jumper has been reinserted into the logbook.
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When a jumper form is initiated, the preparer enters an expected date
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of removal based on his. best. estimate of when removal Lwill occur.
When. the removal of the jumper is. delayed _ due to awaiting repair /
gg replacement parts or in the resolution g. of technical issues, the jumper may remain in place past the estimaced removal date..There is T
currently a backlog of past due jumpers on both units.-
Unit 1 jumper'224 was a temporary piping and filter system used for a c.
flush ; of, the : primary grade water system.
The jumper has now been -
removed except for-a short run of pipe and one valve which remains in
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place awaiting parts.
The jumper was not updated to reflect, the removal of most of the original piping.
d.
Although present during the SNSOC meeting that reviewed _and. approved-Unit 1 jumper 842, the Superintendent of Operations failed to. sign 7-the document after approval.
' e.
The review and approval of all jumpers and temporary modifications by the-SNSOC addresses all potential safety concerns prior to installation of the jumpers or temporary modifications. However, the documentation of these reviews and the written safety evaluations are not clearly defined. Therefore, the safety evaluations may not have appeared adequate.
(3) CORRECTIVE STEPS WHICH'HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
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As an overall approach to the corrective actions,'the Unit'I and Unit 2 jumper logs were reviewed by the SNSOC item by ' item for jumpers that have been in place for longer than 4_ months.
The SNSOC made assignments during this review to the various departments for resolution of the outstanding jumpers and to provide periodic. status updates on their review.
In addition, any jumper that will be required to remain in place for longer than six (6) months will be reviewed by the Safety Engineering Staff to ensure the safety evaluation remains valid.
To address the specific items identified, the following actions have been taken or initiated:
a.
The Unit 2-jumper 176 has been reviewed by Engineering and recommendations have been made for removal.
s b.
Based on the review and resolution process initiated by the SNSOC and the ' resources - and priority assigned to the task, the number of outstanding jumpers should be substantially reduced.
e c.
The Unit 1 jumper 224 was revised to reflect current conditions.
d.
Th'e Superintendent,of Operations verified that he was present during tl'e approval of the' jumper. in question and subsequently signed the form.
e.
The Unit 1 jumpers 879 and 880 have been removed by the implementation of a~ design modification.
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(4)- ~ CORRECTIVE STEPS WHICH WILL BE'TAKEN-TO AVOID FURTHER VIOLATIONS:
In' addition. to 'the activities described in. section 3, the following corrective steps have been initiated:
a.
The SNSOC w'ill continue the review of the jumper. logs for both units on a monthly 'dasis 'until the - past due. jumpers are cleared,and the overall backlog is substantially reduced.-
- b..The guidance for.more thorough documenting safety evaluations will be developed and included in a new administrative procedure.
-c.
The importance of. conducting a thorough and accurate. periodic review of the jumper log will be reemphasized to all Operations supervisory personnel.
A (5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The. administrative procedure for additional guidance on safety evaluations will be completed by May 17, 1984.
The safety evaluation for outstanding jumpers will be completed by July 31, 1984 for all remaining jumpefs in place over 6 months.
The importance of thorough reviews will be emphasized to all Operations supervisory personnel by May 31, 1984.
The Safety Engineering Staff will initiate the review of jumpers in plad*c greater than six (6) months to verify the continued validity of..the safety evaluation.
If necessary, a new safety evaluation will' be performed using the guidance of the revised administrative procedure.
This review will be initiated by May 17, 1984 and is expected. to be completed by June 30, 1984.
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Attcchment P gs 4 Serial No. 227-1 RESPONSE TO " NOTICE OF DEVIATION" INSPECTION REPORT NOS. 50-338/84-04 AND-50-339/84-04 j
NRC COMENT:
'Section 3.5.5. -(Missiles from Compressed Gas) of the North Anna Power Station Units 1 and 2 Updated Final Safety Analysis Report, states, "In the event of a localized. failure, such,as a valve stem,. the compressed gas bottles will not become. rocket-propelled missiles, since they are secured in racks.-
The location of the gas storage facilities in relationship to equipment essential for initiating and maintaining a shutdown precludes =. t he possibility of
' interaction in the. event of an incident..
Contrary. to the above,' numerous pressurized high pressure gas bottles, not secured in racks, have been left unattended / stored in areas contained equipment. essential.for.
initiating.and maintaining a
Additionally, ~ there is not - a formal program to control nonflammable high pressure -gas bottles and the prevalent practice is to loosely secure the bottles with rope.
This deviation applies to both units.
RESPONSE
The gas bottles in question were temporary supplied to support design change work and other on-going routine maintenance activities.
The section 3.5.5 of the NAPS Units 1 and 2 UFSAR refers to the established gas storage areas which support normal plant operations and identifies the design for these permanent gas storage facilities. This deviation is correct, in that, the temporary gas bottles were not subjected to the same level of control as that specified in the UFSAR.
DESCRIPTION OF CORRECTIVE ACTIONS:
As soon as station personnel were notified of this deviation, a walkdown was done in the areas identified and the unneeded bottles were removed.
The temporary supply of bottles needed to continue the work were properly secured.
f The craft personnel were reinstructed verbally by Station Management that the supply of bottles on hand should be only those needed and they must be properly secured at all times.
ACTIONS TAKEN TO AVOID FURTHER DEVIATIONS:
The requirement for. temporary supplies of compressed gas to support maintenance ~and construction activities cannot be avoided.
When used, these temporary bottles must be stored in a proper way and removed af ter the work activity is completed.
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